Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
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